Reflections on Verizon Media’s Global Network Initiative Assessment: Building on a Legacy of Strong Human Rights Governance
Verizon Media is a media and tech company with diverse offerings and brands that share the mission of helping people stay connected, informed and entertained. Through our core business we have opportunities to increase access to information and to connect people across the globe. Together with these opportunities, we recognize that we also have corresponding responsibilities, including the responsibility to respect human rights in our business operations around the world.
Verizon Media (through Yahoo, Inc. (Yahoo)) is proud to be a founding member of the Global Network Initiative (GNI). Within the GNI, we have benefitted from collaboration among a diverse group of stakeholders, including companies, human rights organizations, socially responsible investors, academics and other experts on ways to protect and advance human rights, including free expression and privacy for our community of global users.
GNI’s Independent Assessment Process
As part of its work, GNI developed an accountability framework through a multi-stakeholder process. This framework requires member companies to undergo an independent assessment every other year of the policies and procedures they have in place to support their GNI commitments. The GNI assessment is unique within the ICT sector in that, through the work of accredited independent assessors, GNI evaluates the concrete steps that GNI company member companies are taking to respect the free expression and privacy rights of online users around the globe when responding to government restrictions on speech and requests for user data.
Over the years, and through multiple assessments, the GNI Board has recognized that Verizon Media’s approach to these challenges has evolved and strengthened. Earlier this year, the Global Network Initiative (GNI) released the results of its third independent assessment of our company, and the GNI Board of Directors found that Verizon Media continues to make good-faith efforts to implement the GNI Principles on Freedom of Expression and Privacy, with improvement over time.
Uniquely, our company went through acquisition and integration during this latest assessment cycle and gained important insights on maintaining strategic focus on incorporation of the GNI Principles, and on governance and oversight of human rights issues during a period of significant corporate transition. Set out here are some details about the steps we took and what we shared during the most recent GNI assessment. The sections below relate to the GNI Implementation Guidelines.
Responsible Company Decision-Making
Governance, Oversight and Leadership
In spring 2008, Yahoo took the bold step of creating a dedicated Business & Human Rights Program (“BHRP”) to lead its efforts to make responsible business decisions in the area of human rights, including free expression and privacy. This was the first business and human rights program in the ICT sector and its development coincided with the intensive multi-stakeholder code of conduct negotiations that resulted in the launch of the GNI in fall 2008.
A decade later, after Yahoo’s acquisition by Verizon, Inc. (Verizon), Yahoo and Aol, Inc. (Aol) came together to form Verizon Media. Amidst this period of intense change, it was necessary to determine how to carry forward the company’s human rights commitments. The build-out and scaling of the BHRP was a key priority for senior leaders within our company who wanted to ensure continued responsible management, governance and oversight of human rights matters.
The BHRP was empowered to provide centralized leadership and to advise, from a human rights perspective, on global strategy, business decision-making and internal and external engagement. The BHRP’s structured approach to identifying and managing human rights, guided by the UN Guiding Principles on Business and Human Rights and informed by the Global Network Principles and Implementation Guidelines, was applied across Verizon Media’s suite of brands, and later across all of Verizon. Our executive leadership embraced the team’s approach consisting of seven pillars including executive commitment, a dedicated team, supported by a global cross-functional team of partners throughout the business, working to perform human rights due diligence, including systematic assessments of the human rights impacts of our business decisions. The BHRP also has worked consistently to ensure its work is informed by internal and external experts and other stakeholders.
Today, a core team consisting of senior employees guides, directs and manages the BHRP. The Program’s work is within the remit of the General Counsel, and Verizon’s Board of Directors receives periodic updates prepared by the BHRP on issues related to global human rights risks and opportunities.
Immediately upon the formation of Verizon Media, the BHRP set out on an internal “road-tour” to introduce the function to newly formed and combined teams across the company. In these meetings, the BHRP conducted information-sharing exercises, trainings and briefings to educate employees on its issues and the GNI Principles and also to learn from teams about their work. This informed efforts to partner in managing human rights risks and opportunities.
As part of this effort, the BHRP grew its cross-functional virtual team of employees to provide integrated expertise on global strategy, industry initiatives, business decision-making and internal and external stakeholder engagement. This global virtual team is comprised of senior-level employees from different geographies and different teams, including legal, product, engineering, law enforcement, privacy, advertising and sales, editorial, security, communications, and global public policy. Through this team, the BHRP collects information and also disseminates policies and procedures and ensures that key business and functional partners are informed of the implementation of the GNI Principles and Guidelines.
Free Expression and Privacy
Principles and Process
As a first matter of business, after the establishment of Verizon Media, the BHRP conducted a strategic mapping exercise across the new company against the GNI Principles in order to identify areas of the business, as well as executives, team leaders and front-line employees who would most likely encounter challenges and opportunities related to freedom of expression or privacy in the course of their work. The team identified two priorities as a result of this mapping exercise.
To address these priorities, the BHRP focused on integrating into discussions on the re-alignment and integration of policies and procedures. For example, the BHRP was integrated into Verizon Media’s law enforcement response policies and process, which included both Yahoo and Aol, as well as processes for products, transactions, advertising, privacy and content moderation. The BHRP also trained the product legal team on issue spotting for human rights and on escalation paths and procedures in the very first weeks after Verizon Media formed.
During this GNI assessment cycle, we included Aol for the first time and we presented cases that illustrated Verizon Media’s process for responding to government demands for user information or to remove content. These cases demonstrated how Verizon Media receives, considers and handles government demands, as well as how our teams use escalation procedures when appropriate. Importantly, we selected case examples that would demonstrate to the GNI Board of Directors how seamlessly the GNI Principles and the BHRP itself were integrated into Verizon Media’s law enforcement process. This was due in part to Verizon Media’s adoption of its Global Principles for Responding to Government Requests which incorporated key concepts from the GNI Principles.
Among the cases we put forward in this assessment cycle were requests from five different jurisdictions covering instances where Verizon Media applied its policies to reject improperly served government demands, push back on overly broad non-disclosure orders, remove alleged terrorist content from its platforms, and require clarification of overbroad or insufficient government demands. For example, we shared a case involving a written request from a law enforcement agency in the United States for user data that was not submitted to the appropriate corporate legal entity. As a result, Verizon Media pushed back, denied the request and provided instructions to law enforcement on how process would need to be received to be consistent with Verizon Media’s Global Principles for Responding to Government Requests. This case demonstrated how Verizon Media’s processes worked in the weeks immediately following our corporate acquisition.
A key focus of the BHRP team is transparency. When Verizon Media formed, we quickly published a new BHRP website linked from the verizonmedia.com homepage to share information about our team’s work and initiatives. The site includes information about the BHRP’s structured approach to integrating human rights considerations into business decision-making processes and explains the oversight and governance mechanisms in place for human rights issues at Verizon Media, as well as our GNI commitments and approach to conducting human rights impact assessments.
We also described in this assessment cycle our efforts to launch a new Transparency Reporting Hub for Verizon Media. Our belief is that in today’s environment, where technology, law and policy, are constantly evolving, providing transparency is an important way that our business can contribute to greater understanding of the impact of government action and policy on human rights issues and the role of companies in safeguarding those rights. In order to make our Hub a reality shortly after close, our teams standardized reporting on government requests for user data and content moderation among the brands that make up Verizon Media and sought to produce a new, combined set of disclosures with more information and disclosures than any of our individual brands alone had previously offered.
Multi-Stakeholder Collaboration and Engagement
We engage with a variety of key stakeholders in order to stay apprised of developments in our industry and the impact of our business on human rights, as well as to promote laws, regulations and policies that protect freedom of expression and privacy for our users. We shared information in this year’s GNI assessment about our ongoing efforts to engage in dialogues with governments around the world about existing and proposed legislation and policy that potentially impacts privacy and freedom of expression. For instance, Verizon Media has actively engaged in the debate over content moderation in key markets around the world, participates in the Freedom Online Coalition, and along with other ICT companies and civil society groups in the Reform Government Surveillance group, continued to push for surveillance reform.
The BHRP also leads our multi-stakeholder collaboration and engagement to inform our business operations and to help drive policy development to promote human rights in the technology field. We engage actively with civil society groups and other organizations, both inside and outside of GNI, to discuss shared goals and collaboration to address issues of free expression and privacy in the ICT sector and to respond to challenges that human rights defenders, activists, dissidents, journalists, bloggers, and others face in some of the most challenging environments for internet freedom and human rights.
Toward Improvement Over Time
As the GNI concludes its third independent assessment cycle, it is important to note the progress made and to reflect on the opportunities ahead. Embedding human rights decision-making within companies is an ongoing process of implementation, evaluation and commitment to continuous improvement. Maintaining centralized leadership on these issues can help ensure continuity and attention to the human rights impact of business even as a company undergoes change and transformation. At Verizon Media we embraced this challenge and recognize that continued attention to human rights is an important part of how we earn, build and maintain the trust of our consumers and users. We look forward to continuing to work with stakeholders in and outside of GNI to implement the GNI Principles, and to advocate globally for legal and policy reform that protects human rights and puts users first.
For more information on the Global Network Initiative and its independent assessment of Verizon Media, click here.